Petition for Exemption 333 Petitioner SEVENsCamp, LLC Lynwood Douthett CEO/Senior Producer

Page **1** of **4** December 27, 2015
Docket Management Facility US Department of Transportation 1200 New Jersey Avenue, SE West Building Ground Floor Room W12

- 140 Washington, DC 20590

Petitioner: SEVENsCamp, LLC Lynwood D. Douthett CEO / Senior Producer 4401 Atlantic Ave. Suite 200 Long Beach, CA 90807 Cell: 310 303

-0413 Email: lseven@sevenscamp.com Website: www.sevenscamp.com

**SUBJECT:** Petition for Exemption from 

### H.R.658

- FAA Modernization and Reform Act of 2012 Section 333 and Under 14 CFR 11.81 to Allow Commercial Use of Unmanned Aircraft Systems

1. Sections from which exemptions are sought: Application is hereby made for exemption from:
a. FAA Modernization and Reform Act of 2012, PL 112

-95 FEB. 14, 2012, Section 333 b. 14CFR Part 21, subpart H
c. 14 CFR Part 61.113(a) and (b) d. 14 CFR Part 91: i. 91.103(b)(2) ii. 91.105 iii. 91.109 iv. 91.119
v. 91.121 vi. 91.151 vii. 91.405 viii. 91.407 ix. 91.409
x. 91.417 2. Relief sought:
a. SEVENsCamp, LLC wishes to operate Unmanned Aircraft Systems for commercial purposes to include (but not limited to) closed set motion picture and television filming production, videography, inspections and analyses . This relief is sought becausePetition for Exemption 333 Petitioner SEVENsCamp, LLC Lynwood Douthett CEO/Senior Producer

Page **2** of **4**

commercial use of UAS’s is currently prohibited by law unless performed under an exemption. b. This exemption will cover the following airframes, all of which will weigh less than 55 pounds including payload and energy sources: i. Yuneec Typhoon Q500 4k and Tornado H920 ii. Freefly ALTA

3. Public benefit:
a. Use of UAS technology to obtain imagery, information and data obtained by use of manned flight or manual methods: i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., powerline inspecti on ) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging failures during stack or bridge inspections) ii. Reduces the cost of obtaining such information, which benefits consumers and the economy. iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from manned aircraft. 4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C. b. Aircraft will comply with maintenance and inspection requirements of the manufacture r. All repair and maintenance work will be conducted or approved by qualified personnel such as those authorized by Yuneec and or Freefly (or equivalent), and will require a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log for each aircraft.
c. All flight operations will be conducted by three individuals (the UAS crew) who will maintain verbal communication capability with each other at all times during the flight, and the PIC and VO will remain stationary on the ground during the flight operations. The th ird member of the crew (the videographer) may be mobile on foot. i. A Pilot in Command (PIC) who possess the following credentials:

1. An Airman Certificate issued under 14 CFR 61 (private pilot license) screened by the TSA 2. A third Class medical certificate issu ed under 14 CFR 67. 3. A Bi

-annual Flight review under 14 CFR 61.56 4. A completion of a course of instruction in safe UAS flying conducted by Unmanned Experts Inc. (or equivalent instruction). 5. At le ast 200 cycles and 25 hours of flight experience with a UAS rotorcraft

. Such cycles and hours may be gainedPetition for Exemption 333 Petitioner SEVENsCamp, LLC Lynwood Douthett CEO/Senior Producer

Page **3** of **4** during flights under this exemption if safe distance is maintained from persons in accordance with 14 CFR 91.119. ii. A Visual Observer. d. All flight operations will be conducted in accordance with valid Certificates of Authorization.
e. All Flight operations will comply with the following: i. The manufacture rs Aircraft Flight Manuals and operations guidelines ii. SEVENsCamp flight operations policies including lost communication and other emergency and safety procedures. iii. Conducted in VMC conditions during daylight hours iv. PIC and VO will maintain VLOS at all times.
v. Pre

-flight inspections (including ground control station) and safety risk assessments will be conducted prior to each flight. vi. Flight altitudes will remain below 400 feet AGL. vii. Flight ground speeds will not exceed 50 knots. viii. Not intrude into class B, C or D airspace or published approach, SID or STAR, or take place within 5 miles of an airport. ix. In the event that flight operations require flight within five miles of an airport; before th e start of the flight operation the PIC will first

1. O btain prior permission and clearance from the airport ATC or Airport Management. 2. Obtain a letter of agreement with that airport’s management or otherwise be permitted by a COA issued to the exemption holder. The letter of agreement with the airport management will be made available to the Administrator or any law enforcement official upon request . During such operation, the PIC will maintain in constant radio contact with the airport ATC or the Airport Management through to the completion of the flight operation

. x. Not be made near persons as required in 14 CFR 91.199 and not over persons on the ground without their prior permission. xi. Each flight will be logged i n both the PIC’s logbook and the aircraft logbook. xii. Not to exceed 75% of the battery or fuel capacity of the aircraft or, 30 minutes whichever comes first. xiii. Any incidents will be reported within 24 hours of occurrence to the FAA. xiv. Any accidents will be reported to both the FAA and the NTSB in accordance with 49 CFR 830 Subpart B 830.5, 830.6, Subpart C 830.10 and Subpart D 830.15 (a) and (c)Petition for Exemption 333 Petitioner SEVENsCamp, LLC Lynwood Douthett CEO/Senior Producer

Page **4** of **4**

xv. SEVENsCamp will maintain liability insurance of at least $1,000,000 issued by Transportation Risk Management, Inc. (or e quivalent qualified insurer). xvi. Any applicable local FSDO requirements. xvii. All other applicable regulations concerned with the commercial operation of UAS aircraft. xviii. Aircraft will use 2.4GHz for control of the aircraft, and 5.8 GHz for sending data.

Please advise us of any additional information or changes that are required.
Sincerely,

Lynwood D. Douthett CEO/ Senior Producer SEVENsCamp, LLC